who pity thanks for your reply!!!!
i contacted directly the civil aviation authorities and this is their answer:
"New with Part-FCL is that you need to hold the night rating in addition to the IR rating (c.f. FCL.610(a)(1)(i)), if not your IR priviledges will be restricted to day only (earlier there was some night training included in the IR training, but this training was less than what is required for a night rating).
the night recency to operate at night with passengers on board, you need 1 take-off, approach and landing at night, unless you hold an IR (c.f. FCL.060(b)(2)), so on the recency issue there is no change; if the pilot hold an IR he is consider to have fulfilled the night recency requirements. There is an exception for single-pilot CAT ops at night, which requires a specific recency."